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filed a Form 656, Offer in Compromise (OIC), based on promotion
of effective tax administration, for 1999, 2000, 2001, 2002, and
2003. Petitioner offered to settle her outstanding tax
liabilities, totaling approximately $40,000, for $1,000.
Petitioner’s case was assigned to Appeals Officer Celia
Cleveland (AO Cleveland). AO Cleveland conducted the collection
due process hearing with petitioner and her representative via
numerous telephone conversations and written correspondence.
During the hearing, petitioner did not challenge the existence or
amount of the underlying tax liability for 1999 or 2000.
Based on the documentation submitted by petitioner, AO
Cleveland determined that petitioner’s OIC did not qualify for
consideration as an offer based on promotion of effective tax
administration. Petitioner did not offer any other collection
alternatives other than the OIC. AO Cleveland reviewed
petitioner’s administrative file and transcripts for the years in
issue, and she verified that all applicable laws and
administrative procedures had been met.
On July 22, 2005, the Appeals Office issued to petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 for 1999 and 2000 (notice of determination),
determining that respondent’s filing of the tax lien was proper
and indicating that petitioner’s OIC was rejected. The
attachment to the notice of determination notes that petitioner
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Last modified: May 25, 2011